On November 18, the State E-rate Coordinators Alliance (SECA) filed an appeal with the FCC seeking an Item 21 Attachment deadline waiver for dozens of applicants. Starting in Funding Year 2011, Item 21 Attachments must be submitted by the time the Form 471 window closes. However, the SLD may grant additional time per the “clarification order” that was released on January 14, 2011.

USAC gave thousands of applicants until May 17, 2011 to submit their Item 21 Attachments, and subsequently denied applicants who did not submit the Item 21s by that date. SECA is asking the FCC to waive the rules because FY 2011 was the first year that the Item 21 Attachment had deadlines, and the implementation of this new policy was overly broad and flawed, resulting in much confusion.